NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Yongzhi Financial Investment Co.

EXCHANGE RULES: Rule 432. GENERAL OFFENSES

W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

Rule 534. – Wash Trades Prohibited

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition of wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement that Yongzhi Financial Investment Co. (“Yongzhi”) presented at a hearing on September 28 , 2017, in which Yongzhi neither admitted nor denied any rule violations, allegations or findings upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“Panel”) found that between January 1, 2015 and February 5, 2016, two Yongzhi traders executed a series of trades in COMEX Copper Futures contracts between accounts wholly owned and controlled by Yongzhi. The Panel further found that Yongzhi failed to diligently supervise its traders in a manner sufficient to ensure that they executed the trades in compliance with Exchange rules.

The Panel found that as a result of the foregoing, Yongzhi violated Exchange Rules 432.W and 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Yongzhi to pay a fine to the Exchange in the amount of $55,000.